Testun llawn:
Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy SD1 are of particular interest to our Client. As a result, we
offer the following for the Council’s consideration, and Inspector’s in due course.
The Site and Adjoining Area
This submission relates to the land edged red on Plan A below.
Plan A
The land relates to two residential properties and their associated garden areas (circled red
in Photograph 1 below), positioned to the north and south respectively of Maesglas Road,
Penygroes.
Photograph 1
As can be seen form the photograph above, each property contains a series of outbuildings
manicured lawns and ornamental plants, presenting therefore a very different appearance to
the agricultural enclosures to their north and west. Both properties then gain access directly
off Maesglas Road.
Immediately to the west of each property are two existing residential estates (Brynglas and
Cwrt y Ffynnon), with their associated domestic curtilages. Again, the site subject of this
submission is therefore clearly more akin to the land use to its west, as opposed to that to its
east.
A short distance to the west then is the core of the settlement of Penygroes, with its
associated community facilities and local services and bus stops, all of which are within
walking distance of the site subject of this submission.
Under the provisions of the current adopted Carmarthenshire Local Development Plan, the
site adjoins, but remains outside of the currently defined development limits, as illustrated by
Plan B.
Plan B
Having reviewed the evidence base for the current adopted LDP, it is not apparent as to why
the site edged red in Plan A was excluded from the defined development limits.
2nd Deposit Local Development Plan
Although no submission was made by or on behalf of our Client at the Candidate Stage for
the inclusion of the land edged red in Plan A within the defined development limits for
Penygroes, we understand that the Council undertook a comprehensive review of the
development limits of all settlements within the County as part of its preparation of the 2nd
Deposit LDP. Notwithstanding this assessment, from reviewing the Proposals Map for the
2nd Deposit LDP, the situation with regards to the land in question appears to be unchanged,
as illustrated in Plan C below.
Plan C
As can be seen, despite the ‘on-the-ground’ factual situation of the land in question, it
continues to be excluded from the development limits of the settlement of Penygroes.
Consistency with Other Policies of the 2nd Deposit LDP
The Council has provided no specific indication or guidance on how it has determined and
defined development limits within the Deposit LDP. It has therefore been difficult to ascertain
why some sites have been successfully included and others haven’t, which is discussed
further below. However, Policy HOM3 deals with small extensions to existing rural villages
and so provides a useful series of criteria in determining where such extensions would be
acceptable, namely the following:
Minor infill or a small gap between the existing built form; or
Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
Conversion or the sub-division of large dwellings.
It is logical therefore that the same assessment criteria should be utilised in assessing
whether or not a candidate site would make an acceptable addition to existing development
limits.
Taking the land edged red in Plan A into consideration, together with the actual ‘on-theground’
physical attributes of the two residential properties in question, adjoining and nearby
land and its use, it is clear that it would adhere to the second criteria listed above and so
should in turn have logically been included within the defined development limits of
Penygroes. Its exclusion would be inconsistent with the assessment provisions of Policy
HOM3 and indeed decisions taken by the Authority with regard to other sites within the Plan
area in terms of Policy SD1. As a result and on this basis alone, the Plan as it currently
stands is unsound.
Consistency with Other Development Limits
Consistency in approach and application is critical in order for the planning system to be
both effective and credible to all its users. Without it, the system itself becomes unsound and
in the case of the determination of the development limits for Penygroes and other
settlements, the Council has been found to be inconsistent.
The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Garnant and Llanwrda.
Plan C
(Garnant)
Plan D
(Llanwrda)
In the case of the Garnant example, the property is a modest residential dwelling in a
substantial domestic curtilage, which of course is undeveloped. The property represents the
last in a line of properties, beyond to the east of which is agricultural land and so defined as
‘open countryside’. The Llanwrda example is then an element of an existing larger
agricultural enclosure, with two of its boundaries therefore currently undefined and so
extending the existing settlement’s limits beyond existing boundaries.
It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion is in direct contrast and inconsistency to the
Council’s decision to exclude the land edged red on Plan A from the development limits,
which consists of existing residential properties. The exclusion of it would therefore
represent a clear inconsistency in approach taken by the Council, resulting in the Plan as it
stands being unsound.
In conclusion, this representation to the 2nd Deposit Draft of the Revised LDP has sought to
assess the suitability of the inclusion of the land edged red on Plan A, based on the current
provisions of the Plan and its decisions taken with respect to similar circumstances
elsewhere. In conclusions, it has successfully highlighted that its continued exclusion would
represent a dangerous inconsistency.
We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.
